Anti-Money Laundering Policy

1. Purpose and legal context

This policy applies to company directors, employees and representatives handling business relationships, invoices, payroll, refunds or other funds for LT Marine Offshore Services, Inc. It prohibits knowingly dealing with criminal proceeds or helping another person disguise their origin, ownership or destination. Terrorist financing concerns must also be escalated.

The Philippine Anti-Money Laundering Act, as amended, distinguishes the general money-laundering prohibition from particular duties of legally defined covered persons. A maritime business is not automatically a covered person merely because it makes or receives payments. Management must obtain advice on duties applicable to the actual activity; this policy does not claim a registration, reporting system or regulatory status.

2. Understand the business relationship

Before approving a new commercial relationship, the responsible manager must obtain enough reliable information to understand the other party's identity, business, authority to act and reason for using LT Marine's services. Where ownership or control is unclear or the arrangement is unusually complex, seek further information and management review.

The checks must match the transaction's risk. A small routine supply and a large unfamiliar cross-border arrangement need different attention. Collect only information that is necessary, protect it under our Privacy Notice and do not treat nationality, name or place of birth alone as proof of wrongdoing.

3. Follow traceable payment instructions

• Match the invoice or employment obligation to the approved service, amount, payee and account.
• Independently confirm a new bank account or changed payment instruction through an established contact route; do not rely solely on a reply to the message requesting the change.
• Escalate requests to use an employee's personal account, an unexplained third-party account or a payment route unrelated to the service.
• Do not split payments, falsify invoices or describe funds inaccurately to avoid scrutiny.
• Verify the reason and destination of any refund rather than automatically sending an overpayment to a different account.

4. Warning signs and escalation

Warning signs include unexplained cash, repeated overpayments, inconsistent documents, pressure to act before normal checks, a payer refusing reasonable identity questions, or transactions with no credible commercial purpose. One sign is not a finding of crime. Consider the facts and record the reason for concern.

Refer an unresolved concern promptly to management before approving the affected transaction. Seek advice about any lawful restriction or external reporting duty; an internal concern alone does not give an employee authority to confiscate funds or disclose private information. Assess legitimate crew welfare and wage obligations when deciding how to manage an interruption. Do not alert others to a confidential report where doing so would breach law or prejudice an investigation.

5. Records, reporting and oversight

Keep accurate supporting records of the checks, payment instructions, approvals and resolution. Apply the retention requirements relevant to the record and preserve material required for a lawful investigation; this policy does not set a universal financial-record retention period.

Use our Speak Up & Whistleblower Policy if management involvement is a concern or another reporting route is needed. Honest reports are protected against retaliation. Management must assign responsibility for applying this policy, give relevant staff guidance and review concerns, changes in activity and corrective measures. Breaches are subject to fair review and appropriate action under applicable law.